As introduced in Luxembourg 2015 budget, the country is planning to strengthen its transfer pricing provisions from 1 January 2015. Currently, Luxembourg generally follows the OECD transfer pricing guidelines, but has no detailed regulations.
The main transfer pricing provision under current law is that transactions between related parties be carried out in line with the arm's length principle. If a transaction with a related non-resident party is non-compliant, the tax authorities may dete…